Privacy Policy

Last updated:

Integrity Compliance 360 Inc. ("Company", "we", "our", or "us") respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through selfexclude.io (our "Services") and our practices for using, maintaining, protecting, and disclosing that information.

Scope of This Policy

This policy applies only to information we collect:

Through the Services
In communications, including email, text, chat, and other electronic messages, between you and the Services
When you interact with our applications (including mobile apps) on third-party websites and services
From third parties, including CFTC-registered prediction market operators, business partners, identity verification services, and regulatory bodies with whom we share data to facilitate self-exclusion
Offline, such as through physical mail or telephone communications with us

It does not apply to information collected by:

Us through any other means, including on any other website operated by Company or any third party that does not link to this policy
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Services

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes is deemed to be acceptance of those changes.

Children's and Minors' Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

"Personal data" is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, social security number, date of birth, government-issued identification number, or unique trading account identifiers.

The types and categories of personal data we collect or process include:

Account and contact information: Name, address (home, work, or other), email address, phone number, username, and other contact information
Account history: Information about your subscription, account, transactions, purchases, order history, or discounts
Device information: IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings
Content and information: Data you elect to provide as part of your profile
Identity document information: Social Security and driver's license numbers
Demographic information: Date of birth, citizenship, and gender (used strictly for identity verification and regulatory reporting purposes)
Third-party account details: Usernames, account IDs, handle identifiers, or wallet addresses associated with your accounts on CFTC-registered prediction market platforms

Some of the information identified above, including identification document information, may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.

Statistical and Technical Information

We also collect:

Statistics or aggregated information: Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data
Technical information: Information about your internet connection and usage details about your interactions with the Services, such as clickstream information, products that you view or search for, page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from a page

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account, submit a request for self-exclusion, verify your identity, contact us for customer support or technical assistance, respond to surveys or feedback requests, or communicate with us regarding potential violations or enforcement actions.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, browser type, and information collected through cookies, web beacons, and other tracking technologies.

The technologies we use for this automatic data collection may include:

Cookies: A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device
Web Beacons: Small electronic files (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company to count users who have visited those parts and for other related statistics

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as identity verification providers, email platform providers, content delivery services, analytics, security and anti-fraud services.

We also may receive personal data from our business partners, including CFTC-registered prediction market operators, to share consumer information necessary to enforce your self-exclusion, including your account status, unique user identifiers (such as handles or wallet addresses), and trading history.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

Provide you with the Services and any contents, features, information, products, or services that we make available
Process and manage your self-exclusion registration, including verifying your identity and eligibility to participate
Fulfill any other purpose for which you provide it
Provide you with notices about your account or self-exclusion status, including confirmation of enrollment, potential expiration, and renewal of your exclusion period
Improve our Services, including by analyzing your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services
Provide you with information regarding responsible trading resources, educational materials, or changes to regulatory protections that may affect you
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us
Notify you when Services updates are available and about changes to any products or services we offer
Communicate your self-exclusion status and relevant identity details to CFTC-registered prediction market operators solely for the purpose of restricting your access to their platforms
Comply with applicable federal, state, and local laws, regulations, and legal processes
Detect, investigate, and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates
To contractors, service providers, and other third parties we use to support our organization who are bound by contractual obligations to keep personal data confidential
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets
To fulfill the purpose for which you provide it
To CFTC-registered prediction market operators solely for the purpose of enforcing your self-exclusion, blocking access to trading platforms, and maintaining regulatory compliance
To identity verification partners for the specific purpose of validating your government-issued identification and eligibility to register for self-exclusion
To government or regulatory bodies, such as the Commodity Futures Trading Commission (CFTC), when necessary to report on self-exclusion metrics, facilitate audits, or comply with legal obligations
For any other purpose disclosed by us when you provide the information
With your consent

We may also disclose your personal data:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request
To enforce or apply our Terms of Use and other agreements
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our partners, or others

Your Rights and Choices About Your Information

Cookies and Other Tracking Technologies

You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

Access and Data Portability: You may confirm whether we process your personal data and access a copy of the personal data we process
Correction: You may request that we correct inaccuracies in your personal data that we maintain
Deletion: You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law
Opt Out: You may request that we do not use your personal data for targeted advertising, profiling, or sales

To exercise any of these rights, please email contact@ic360.io. To appeal a decision regarding a consumer rights request, please email the same address.

Some browsers and browser extensions support the Global Privacy Control ("GPC") that can send a signal to process your request to opt out from certain types of data processing. When we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the "last updated" date and posting the updated policy on the Services.

CCPA Privacy Notice for California Residents

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information, including the specific pieces of personal information we have collected about you. You may exercise your right to know twice in any 12-month period.

Right to Delete and Right to Correct

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations. You also have the right to request correction of personal information we maintain about you that you believe is inaccurate.

Right to Limit Sensitive Personal Information Use

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA's Permitted SPI Purposes.

Personal Information Sales or Sharing Opt-Out

You have the right to request that businesses stop sharing your personal information at any time, including through a user-enabled opt-out preference signal.

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at:

Email: contact@ic360.io

To register a complaint or concern, please email contact@ic360.io.